Q: What is the difference between a rare burger and a rare steak?

The E.coli 0157 (that nasty pathogen that can kill) exists on the outside of the muscle cut, so it’s essentially on the surface of the meat. When you cook a steak, you cook off/kill the pathogens which makes the steak safe to eat. When you mince a joint of meat, you mix up the outside and the inside, thus pushing the pathogens through the meat. If you then don’t cook the meat thoroughly you don’t kill off the pathogen, making the burger potentially dangerous.

Q: Why haven't the FSA banned rare burgers if they're dangerous?

They’d probably like to as their main role is to protect the public, but they accept that if you can put in processes that reduce the risk to an acceptable level, and which can be risk assessed effectively, then some businesses could potentially sell safe pink burgers. The responsibility to be safe remains with the business, but the FSA are concerned that some businesses will not have the knowledge, capacity or inclination to mitigate the risks accordingly.

Q: Is it illegal to sell undercooked, raw or pink burgers?

No, it’s not currently illegal, however, the CRITICAL control point (CCP) for meat is to cook it through. That means you have to cook it to a core temperature of 70 degrees for 2 minutes. If you don’t have a critical control point you are potentially serving unsafe food so you’ll have to either find a CCP to make the meat safe other than cooking it, or find another acceptable time/temperature combination. The FSA continue to state that THE ACMSF advice to cook to 70 degrees for 2 minutes is sound and will allow for a six log reduction in the pathogen.

Q: Blimey! What's a six log reduction when it's at home?

If you want to sell pink burgers you’re going to have to get your head round some pretty serious microbiology. A six log reduction means the number of germs is 1,000,000 times smaller after a process such as cooking to 70 degrees for 2 minutes is completed.

The FSA & ACMSF state that a six log reduction is what businesses should be achieving. However, since the whole rare burger issue appeared on the scene, the FSA has stated that a four log reduction could be acceptable if the business has an otherwise robust HACCP-based food safety management system in place, which includes measures, alongside any cooking process, to minimise or reduce the bacterial loading of the mince used AND suitable signage top warn customers about the risks. A four log reduction means that the number of germs is 10,000 times smaller after the process.

Q: What's all this about signage?

In the good old US of A you can get pink burgers all over the place (they also have higher E.Coli infection rates). They can do this because they treat the meat differently from the point of slaughter but also because they inform the customers of the increased risk of undercooked meat through effective signposting. ‘You can eat this but please know it might kill you’ would be a slightly flippant example I’ve just come up with. However, the FSA have asked us to feed back to them with proposed signage for our members (so if you have any good ideas on this, please let us know).

Q: What actually are the risks?

Pretty significant, death being one example. E.Coli can be pretty nasty stuff, it’s also a low dosage pathogen, so you don’t need much of it to cause serious a life changing injury or death.

Q: Are there any ways to cook pink burgers with a six log reduction?

Yes. There’s sear and shave, sear and grind and potentially also with a sous vide if you use the right time / temperature combination. All of these are approved methods but these methods aren’t popular with businesses as they mean changing their processes and are likely to increase costs. But the FSA are more than happy for these methods to be employed as long as the application matches the food safety management system. If you use these methods you can cook pink burgers although you may have to charge a bit more for your food.

Q: Can't I just get round this by buying high quality meat?

It’s the slaughter as much as the meat quality that’s important here and it is assumed that all meat leaving British slaughter houses and cutting plants is infected – regardless of whether it is locally sourced, organic, free range or some other signifier of quality.

Q: So how can restaurants sell steak tartare then?

Well this is a bit iffy to be honest, but this is seen by the EU as a culturally important dish, giving it special protection. There is an EU classification of meat that can be sold raw, however, the FSA are not convinced this makes it safe or that you can buy such safe produce in the UK. Furthermore, steak tartare is usually produced using sear and shave.

Steak tartare is also not nearly as popular as burgers. If restaurants started selling thousands of portions of steak tartare a week, the FSA would likely be more concerned. With millions of burgers sold in the UK each year, it would greatly increase the likelihood of E.Coli outbreaks if a significant number of those burgers were sold pink.

Q: Why can I buy pink burgers in some places and not in others?

Well hopefully the places you can buy them are achieving either the 6-log or 4-log with suitable signage. But the reality is that some local authorities are following the ACMSF advice to the T, while others are more accepting of the 4-log approach. This means that the location of the food business may have as much to do with whether they are allowed to sell pink burgers or not.

It’s quite a big step to ask the FSA and local authorities to allow food to be sold, when they are far from convinced that it is safe and so some are refusing to allow pink burgers to be sold. In their defence, many of the pink burger producers are not achieving 4 or 6 logs reductions or giving the EHO’s confidence in them or their processes when they visit.

Q: What happens if I sell them anyway?

Well apart from potentially killing your customers (which is never good for business!), you might find you’ve invalidated your insurance, you could be sanctioned by local enforcement team and could end up in an expensive court case with fines and even potentially jail time.

Q: What do I do now?

Well the responsibility lies with you, the food business operator. You need to either look into the approved 6-log production methods, develop systems and methodology that will enable the 4-log reduction or just cook your burgers through. 

We are looking into different processes and methodology which might have the desired effect and asking NCASS members to sign up to our rare burger scheme so we can look at your validation processes and look into getting them checked out. To sign up email mark@ncass.org.uk.

The FSA are carrying out microbiological tests and will report back later in 2015 with their findings and have just produced updated advice to local authorities. By the time this article goes to print, the FSA board who are meeting in September to consider the rare burger situation, will have discussed the situation again although not necessarily come to any definitive conclusions.

Q: How can NCASS help me?

We will continue with our work with our own and other Primary Authorities to help to find acceptable solutions as well as representing your concerns to Local Authorities and the FSA. If we can find safe and acceptable methods, we will endeavour to get this ‘Assured’ by our Primary Authority so that you can use those validated methods. We are also feeding back information on potential signage.

But we can’t help you if we don’t know you are selling, or planning to sell pink burgers, so give us a call and let us know so we can work with you to improve the safety of the food you sell or are planning to. Of course, we will not share your methodology with other businesses either.

MEMBERSHIP

We'll help with your legal responsibilities and simplify your compliancy obligations.

Find out more Request a call back